Marangos And Hadjipapa LLC

24th May 2018

A. Marangos & A. Hadjipapa L.L.C is a lawyers’ limited liability company established in Cyprus with registration number ΗΕ 325801 (also referred to herein as ‘we’, ‘us’, our’, the ‘Firm’ or ‘Marangos & Hadjipapa’) which is committed to the maintenance of your privacy and the handling of your personal data in an open and transparent manner.

To whom this notice is addressed to:

This privacy notice is addressed to natural persons who may be one or more of the following:

- current and potential customers of our Firm or persons who have had a business relationship with our Firm in the past;

-Authorized representatives or agents of beneficial owners of legal entities administered by the Firm;

-Officers or employees of legal entities to whom we provide services

Aims of this notice

Therefore, this privacy notice aims:

a)    To provide information about the nature of the personal data which we may collect and process from you and the purposes of such processing;

b)    To inform you about your rights with respect to the data concerning yourself that you communicate to us under the EU General Data Protection Regulation and Cypriot data protection law;

c)     To inform you with respect to the instances whereby we may transmit your personal data.

What constitutes ‘personal data’?

Personal data means any information relating to an identified or identifiable natural person. Examples of such personal data are your name, address and identification number and the form of such data may be hard copy, electronic, or other form.

What constitutes ‘processing’ of personal data?

By ‘processing’ of personal data, we refer to any operation which is performed upon them by us, for example their collection, recording, organization, storage, disclosure, transmission, erasure or destruction.

What personal data we process and where we collect it from

We collect and process different types of personal data, depending on the type of service that you requested to receive, be it legal, corporate administration or other relevant or ancillary services and our legal and regulatory obligations in the field of anti-money laundering legislation and tax legislation and other applicable national or international legislation.

Personal data may be collected either from the client directly, or from their representatives, employees or agents. We may also collect and process personal data from publicly available sources, such as governmental agencies, the internet, or the press.

For the above purposes, the types of personal data that we collect customarily include, but are not limited to the following:

-Name, address, contact details (telephone/email), identification data, birth date, place of birth, marital status, CV, source of wealth, tax registration codes/numbers, employment status, information on business activities, data concerning any criminal convictions, information on whether you hold/held a prominent public function, FATCA/CRS information.

Data of minors (children)

We acknowledge that safeguarding the privacy children/minors is of particular importance. Any personal data concerning children will be collected only to the extent necessary depending on the type of service that you requested to receive and provided that we obtained the consent of the parents/guardians of such children or otherwise permitted by applicable law. 

Why your personal data is collected and the legal grounds for doing so

It follows from the above, that in order that we may be in a position to provide any of our services to you, you must provide us with such personal data which are necessary in order to enable us to do so, but also in order to abide by the legal obligations which we are bound by, as mentioned above.

Specifically, the legal grounds based on which we may collect and process personal data are determined by the EU General Data Protection Regulation and Cypriot data protection law and may be based on one or more of the following reasons:

a)    For the performance of the purpose of our engagement by you, i.e. to provide legal, corporate administration or other relevant or ancillary services as per our engagement and complete our client acceptance/KYC/anti-money laundering procedures.

b)    For compliance with a legal obligation: As a lawyers limited liability company and the provider of legal corporate administration or other relevant or ancillary services to local and international clients, we are bound to abide by several pieces of legislation, including but not limited to the Anti-Money Laundering Law, Tax Laws, Cyprus Banking Law and other pieces of legislation which are directly relevant to our activities. We are also licensed and supervised by the Cyprus Bar Association and as such we are obliged to adhere strictly to its guidelines on several matters pertaining to our business.

The above impose on us necessary data processing activities concerning our clients and their agents/representatives such as KYC/due diligence obligations, tax laws, reporting obligations and compliance with directives and court-orders.

c)     For the safeguard of our legitimate interests such as initiating legal claims or assistance in connection therewith, preparation of our defence in litigation procedures, internal management of systems and organization of our work, prevention of anti-money laundering.

d)    You have provided us with your specific consent for such processing other than for any of the reasons set out above, in which case your consent constitutes the lawful ground of processing of personal data. You have the right to revoke such consent at any time.

Who may be recipients of your data/ transfers of data outside European Union

We may transmit your personal data in the context of us providing the agreed services to you or in accordance with statutory obligations imposed on ourselves and/or the third-party recipients.

For example, we may transmit your data to certain service providers and vendors or government authorities such as:

-The Cyprus Registrar of Companies;

The Cyprus Commissioner of Taxation;

-The Civil Registry and Immigration Department;

-Accountants and Auditors;

-Credit institutions in Cyprus and abroad where you requested the opening of bank accounts/provision of banking facilities or that need to be provided with information in the context of a transaction relating to yourselves personally or companies owned legally and/or beneficially by you;

-Company agents in foreign jurisdictions who maintain records of companies owned legally and/or beneficially by you

Additionally, we may transmit your data as necessary to abide by any court order or as otherwise legally required.

In the context of the above, we may transfer your personal data to countries outside the European Union for the purposes mentioned above, if required by law, or if you have given us your consent to do so. Recipients located in countries which are deemed not to afford an adequate level of protection of personal data are obligated to maintain appropriate safeguards in relation to the transfer of your data to them as per the relevant provisions of the EU General Data Protection Regulation.

Retention of Personal Data

We will keep your personal data for as long as we maintain a business relationship with you and we provide you with services.

Once our business relationship stops and we cease to provide you with any services, then the data shall be kept for a period of 5 years from such cessation, as per the relevant anti-money laundering legislation.

Your rights

You have certain rights (which may be subject to limitations or restrictions) under the applicable legal framework such as:

-The right to request access to and rectification or erasure of the personal data we hold about you;

-The right to obtain restriction of processing or to object to the processing of the personal data we hold about you; and

-The right to receive a copy of the personal data we hold about you.

-The right to lodge a complaint about the processing of your personal data to your local data protection authority.

Where the Firm is legally required by law to process such data then such legal obligation imposed upon the Firm will override your rights, and the Firm hereby reserves all its rights under applicable law.

Amendments to this Notice

We will communicate any updates or amendments to this Notice to you as may be necessary.

Enquiries/ Requests/ Concerns

Any enquiries, requests or concerns regarding this Notice or relating to the processing of your personal data should be addressed to mhadjipapa@lawmar.com.cy. (telephone: + 357 25 543 000).